Dear IAAC, Minister Dabrusin and Minister Hodgson,  

I am writing to express my strong support for an impact assessment (IA) with a joint review panel of the Deep Geological Repository (DGR) proposed by the NWMO.

The project depends on transporting high-level radioactive waste from nuclear reactors in Ontario, Quebec, Manitoba, and New Brunswick over a period of up to 50 years, therefore transportation MUST be examined within the IA and by the joint review panel.

The currently proposed project ignores Indigenous rights and risks to communities along the cross-Canada transport route - this must not be allowed.

This project involves the transport and management of the most toxic, long-lived form of pollution known to the planet. That is exactly why it must undergo a full IA and attract the highest level of public scrutiny.

In supporting an IA for this project, the following concerns must be remedied if the project is to proceed in a way that allows for a cumulative review of impacts.

Any attempt to exclude transportation from the IA creates a misleading picture of the project’s true impacts and shields core decisions about transport routes, accident risks, and emergency preparedness from public scrutiny.

This is a project that inherently spans many provinces, Nations and communities and their respective rights. A federal IA is uniquely placed to assess the project’s malfunctions and accidents - including those that are incidental to or directly linked to the project. The transport of nuclear waste must not be allowed to escape review. 

The NWMO in their proposal documents fall short of recognizing Canada’s commitments under the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) and the domestic United Nations Declaration on the Rights of Indigenous Peoples Act. But the IAA requires consideration of Indigenous rights and Indigenous knowledge, and reaffirms Canada’s commitment to seek the free, prior, and informed consent of Indigenous peoples in relation to decisions under the IAA.

Canada is now facing the consequences of decades of nuclear decision-making that failed to meaningfully examine end-of-life realities, with the fate of some 5.9 million fuel bundles of high-level radioactive waste raising serious concerns of ongoing social and environmental risk.

The IA for the project must apply an environmental justice lens.